February 6, 2016
US Department ofTransportation, Docket Operations West Building, Ground Floor, Room W12-140 Washington, DC 20590 Re: FAA Exemption Rulemaking Section 333 ofthe FA Reform Act and Part 11-14C.F.R. 

### & 45.22(b); 14 C.F.R. Part 21; 14C.F.R. 61.113(a) 

### & (b) (2); 91.109; 119.121; 91.151(a); 91.203(a) 

### & (b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) 

### & (b) Dear Sir or Madam: I, Jeffery E. Cook, am requesting an exemption from the Federal Aviation Regulations ("FARs") listed belowand pursuanttothe FAA Modernization and Reform Act of2012 and the procedures contained within 14C.F.R. 11so I may commercially operate a small ultra lightweight unmanned aircraft system ruAS"), specificallythe DJI Phantom Ill Professional and the DJIInspire 1 Professional orthe equivalent and crewforthe purpose ofphotography and videography ofcommercial and residential properties. I have been a UAS hobbyistforoverthree years without incident. I am applyingforthis exemptionto allow me to legally perform aerial photographyand videography contract workfor real estate agencies, private individuals, photography and video organizations, and anyotherentitythat may desire aerial photography and videography. As an informed hobbyist, I understandthe importance of pre-flight, inflight, and post-flight safety measures to ensure the public and my safety. A grant of myexemption request by the FAA would permitoperations ofthe specified UAS in predetermined areas awayfrom the general public, airports, heliports, and vehiculartraffic; primarily over individual properties and communities forthe purpose of recording real estate listings. All flights shall be logged and recorded to minimally include the date and time oftheflight, name ofthe pilot, visual observer, address or location oftheflight, duration oftheflight, weatherconditions, and any other pertinentflight notesto include the altitude and speed along with signatures ofthe pilot and observer. A copy ofthe images recorded shall be retained for a minimum of 12 monthsform the date of the flight. In summary and in accordance with this request ofexemption as authorized and outlined bythe FAA under section 333{c) ofthe Reform Act specified for the use of UAS for "Real Estate" purposes, IJeffery E. Cook will adhere to all FAA regulations at all times and shall conduct all flight operations in strict compliance ofall safety protocols as mandated and required by regulations and best practices. I request the grant ofexemption to operate the above specified UAS for commercial purposes as described in this request and allowable by law. This grant ofexemption will allow me to offer my services to real estate professionals, private individuals, and any other organization requiring aerial photography and videography who do not have the required knowledge, experience, or certification to operate a UAS safely and in compliance with FAA regulations. The essence ofthis application is that I, Jeffery E. Cook, meet and exceed the FAA's expected competencyfor piloting UAS for commercial purposes and that my UAS meets and exceeds the safety requirements setforth by the Secretary ofTransportation thereby prompting my request for COA under Section 333.1. Contact Information: Jeffery 

### E. Cook 242 Charleston Court Fort Mill, S.C. 29707 704-219-4346 jeff@jeffcookphotos.com 

### 2. The specific sections of 14 C.F.R. I seek exemption from are

- 14 CFR 21;

- 14 C.F.R. 45.23(b)



### - 14CFR 

### 61.113 (a) 

### & (b)

- 14 C.F

### .R. 91, et seq;

- 14CFR 407 (a) 

### & (1)

- 14 CFR 409 (a) (2) and,



### - 14CFR 

### 417 (a) 

### & (b) 3. The extent and reason of relief I seek: 

### 1, Jeffery E. Cook, am seeking relieffrom existing FAR's that currently prohibit my use of UASs from operating commercially for the purpose ofaerial photography and videography in accordance with the FAA Modernization and Reform Act of 1012-112 P.L. 95 

### &331-334. Accordingly, all flights will be conducted with a Pilot In Charge and Visual Observer in accordance with FM Policy N 8900.227 Section 14 "Operational Requirements for UAS's" and with the following restrictions:
a. All aircraft will be made with a UA Gross weight ofless than 55 pounds. Myexemptions request is for an aircraftwith a weight less than 5 pounds. b. All flights will occur only during daylight hours.
c. All flights will occur at or below 400 feet AGI. d. 5 nautical miles from an airport having an operational control tower;
e. 3 nautical miles from an airport with a published instrumentflight procedure but not an operational tower; f. 2 nautical miles from an airportwithout a published instrumentflight procedure or operational tower; or g. 2 nautical miles from a heliportwith a published instrument procedure. h. For safety, no flight with winds over 10 miles per hour 

### i. Flight only in GPS mode which allows UAS to hover in place when radio controls are released.4. How my request will benefit the public as awhole: Aerial photography is a critical component ofmarketing commercially available property. With today's high tech internet market and ever demanding consumer, it is more importantthan everfor realtors to stay ahead ofthe curve by utilizing any and all available technologyto grab the attention ofthe potential buyer. The use of UAS forthese photography and videography services is much safer and more cost effective than attemptingto capture these photos and videos via manned aircraft. Further, there are not enough certified UAS pilots to cover the growing demand for these photos and videos, which ultimately results in untrained/unqualified operators and increased risks due to lack ofsafety knowledge. 

### 5. Reasons whythe exemption would not adversely affect safety; or howthe exemption would provide a level for safety at least equal tothe existing rule: An exemption 

### would not adversely affect the safety because this application applies only to aircraft characteristics and applications within FAA specified limitations. These limitations provide for at least an equivalent safety standard. My past experience with UAS as a hobbyist allows meto utilizethis experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose and experienced operatorthat has the knowledge and skills necessary to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned services to the market place, there will be less ofa demand for manned operations, which will provideforsafer and quieter residential photography and videography. 

### 6. In Summary I, Jeffery E. Cook, request thatthe FAA grant my exemption request and furthervolunteerany information gathered during flights in the event the FAA is interested in live field data. I do agree to attestto adhere to anyfurther limitationsthe FAA imposes, nowor in the future. Satisfaction ofthe current criteria provided in Section 

### 333 ofthe Reform Act of 

### 1012- size, weight, speed, operating capabilities, proximityto airports and populated areas and operation withinvisual line ofsight and national security provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofmy UAS for commercial purposes. I lookforward to supporting the FAA and UAS community in the quest to establish proper regulations and protocols for the safe introduction ofunmanned aircraft into the national airspace.

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